GILTI, global intangible low-taxed income, is a category of controlled foreign corporation income that U.S. shareholders must include in their own income each year under rules enacted in 2017, even if nothing is distributed.
Individuals face it at ordinary rates unless they make a Section 962 election to be taxed like a corporation. Recent legislation adjusted the deduction and foreign tax credit rules; check the current-year computation.
Why it matters: for an individual owner of a profitable foreign company, GILTI can create U.S. tax on money that never left the company.
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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.
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